and the other at Sand Ridge State Forest. Affected and interested parties 

 were given up to 5 October 1978 to comment on the proposal. Monsanto was 

 clearly affected, as part of the proposed critical habitat included not 

 only their property but also some of the actual plant facility. Further, 

 upon review of the Brown and Moll (1979) status report, they questioned 

 the objectivity of certain sections of the report, particularly in regard 

 to unsupported allegations suggesting chemical contamination of Spring 

 Lake and air pollution. 



It was at this point that we (LGL) were asked by Monsanto to evaluate 

 the proposal and supporting documentation, addressing three specific 

 questions: 



1) Is the systematic status of the Illinois mud turtle known 

 with certainty? 



2) Is the population status of the Illinois mud turtle 

 adequately defined by available information? 



3) Assuming an endangered state, do plant site properties and 

 adjacent properties represent critical habitat for Illinois 

 mud turtles? 



Following review of all available published and unpublished 

 information as well as consultation with area experts and a series of site 

 visits, a preliminary report addressing these questions was presented in 

 September 1978, a report which also provided pre-study recommendations 

 (Springer et al., 1978). It was determined that the systematic status of 

 the Illinois mud turtle was not resolved and that the current population 

 status and distribution were even less well known. Based upon existing 

 conditions. LGL proposed a reduction in the proposed critical habitat at 

 Big Sand Mound. With respect to Monsanto property, it was suggested that 

 critical habitat should include all of Spring Lake and Monsanto Bay but 

 not a connecting channel and mud flat north of Monsanto Bay which had been 

 included as critical habitat by OES. The mud flat area collected runoff 

 from the plant and was adjacent to a railroad tankcar storage area, such 

 that it could have been subject to accidental spills of chemicals. We 

 advised that the mud flat was not suitable turtle habitat and should be 

 diked and filled to preclude use by turtles. 



Other immediate management recommendations included: (1) that 

 Monsanto develop a means for diverting water from the Mississippi River 

 into Spring Lake in order to maintain water levels in the pond (if 

 desired) without detrimentally affecting the underground aquifer, (2) that 

 the apparent areas of turtle habitat on Monsanto property be fenced and 

 posted as a wildlife preserve and (3) that predators be removed during the 

 winter of 1978-1979. We reviewed these recommendations with interested 

 state and federal representatives who indicated that they thought the 

 recommendations were appropriate. All recommendations were followed. 



I 



